CBP Starts Voiding Importer of Record Numbers on September 18

If the address, email or phone on your CBP Form 5106 is not genuinely yours, CBP can void your IOR number outright — and the notice goes to whatever email is already on file.

On August 19, 2026 CBP published a notice announcing the first concrete enforcement step under Executive Order 14411, Strengthening Customs Enforcement. CBP is reviewing the CBP Form 5106 data on file for every importer of record, and beginning September 18, 2026 it will void the IOR number of any importer whose information is incomplete or inaccurate.

A voided IOR number is invalid for any purpose — including entering merchandise into the United States. This is not a fine you pay and move on from; it stops your imports until it is fixed.

The three fields that will get people voided

The notice names them explicitly, and each rules out a shortcut that is common in practice:

• Physical address. It must be the actual physical location of the business or individual. It cannot be a registered agent, a customs broker, a freight forwarder, a P.O. box, a business service center, or the address of any other person or entity. For a small company, the principal's home address is acceptable — someone else's office is not.
• Email address. It must be valid and belong to the importer. A broker or third party may not put its own email, or anyone else's, in that field.
• Phone number. Same rule. The number must belong to the importer.

There is a fourth requirement aimed at the paperwork behind the form: a customs broker must hold a power of attorney executed directly with the importer, not routed through a freight forwarder or another intermediary (19 CFR 111.36(c)(3)).

The notification trap

CBP will send written notice of a voiding to the email address the importer most recently submitted, copying the broker that last filed an entry. Read that alongside the rule above and the problem is obvious: if the email on file is the wrong one, the notice goes to the wrong place. The importers most likely to be voided are exactly the ones least likely to hear about it — the first sign will be an entry that will not go through.

It does not necessarily stop at voiding

The party who certifies the form can face fines or imprisonment under 18 U.S.C. 1001 for an intentional false statement. Because IOR data bears on who owes duty, CBP also flags exposure under the False Claims Act. Brokers who transmit information they know or should know is false face penalties under 19 U.S.C. 1641, and are expected to exercise due diligence under 19 CFR 111.29(a) and 111.32.

What to do before September 18

Ask your customs broker to pull the CBP Form 5106 currently on file for you and read the three fields above. If any of them is a forwarder's address, a broker's email, or a phone number that nobody at your company answers, correct it now — an update filed before enforcement starts is housekeeping; the same correction after a voiding is a reinstatement request.

If a number does get voided, CBP's notice explains how to ask for reinstatement, and questions go to CBP with the subject line Enforcing IOR Accuracy. The importer, or a broker holding a valid power of attorney, can make that request.

We do not file the CBP Form 5106 — your customs broker does, and none of our customers list our address or our email on theirs. What we can do is tell you which broker filed each of your entries, so you know who to ask. If you import through a foreign IOR structure, our earlier piece on tighter rules for foreign importers of record covers the bonding and CTPAT side of the same executive order. Ask us anything about it.

Also on this quarter's calendar, unrelated to the above: the customs user fees that sit on every entry change on October 1.